I am contacting you today because I have obtained information which
leads me to believe that experimentation performed on primates at the
University of Alabama, Birmingham, has violated several provisions of
the federal regulations governing the use of animals in experimentation.

Sec. 3.83 Watering -- Potable water must be provided in sufficient
quantity to every nonhuman primate housed at the facility. If potable
water is not continually available to the nonhuman primates, it must be
offered to them as often as necessary to ensure their health and
well-being, but no less than twice daily for at least l hour each time,
unless otherwise required by the attending veterinarian, or as required
by the research proposal approved by the Committee at research
facilities.

The Guide for the Use and Care of Laboratory Animals
from the Institute of Laboratory Animal Resources of the National
Resource Council states:

“ . . . animals should have access to potable, uncontaminated
drinking water according to their particular requirements.”

According to the Guidelines for the Care and Use of Mammals in
Behavioral Research (National Research Council) the fluid needs of
non-human primates are extensive:

The use of fluid reward during experimentation, and the accompanying
deprivation of water within a research protocol at the University of
Alabama, Birmingham, is a serious concern. The recent research protocol
titled: FMR Imaging of Eye Stabilization Processes says

“Water access will be restricted to 3 - 5 hours per day in the lab”
this limited access to water could potentially be a violation of the
watering requirements of Sec. 3.83. Water deprivation of as much as 21
hours per day has the potential to be extremely stressful to these
primates as well and so this could violate:

Sec. 2.36 Annual report.
b) The annual report shall: (7) State the common names and the numbers
of animals upon which teaching, experiments, research, surgery, or tests
were conducted involving accompanying pain or distress to the animals
and for which the use of appropriate anesthetic, analgesic, or
tranquilizing drugs would have adversely affected the procedures,
results, or interpretation of the teaching, research, experiments,
surgery, or tests. An explanation of the procedures producing pain or
distress in these animals and the reasons such drugs were not used shall
be attached to the annual report;

This kind of severe deprivation would clearly cause distress in these
animals. Yet, the University of Alabama, Birmingham, has not reported
any primates as experiencing unrelieved pain or distress. And so the
University of Alabama, Birmingham, has also violated Section 2.36 of the
Animal Welfare Act.

Therefore, I am filing an official complaint against the University
of Alabama, Birmingham, and asking that USDA/APHIS/REAC immediately
investigate this facility to examine the health and welfare of all
primates at this facility as well as the reporting of this facility
regarding the us of animals in experiments that can potentially cause
pain or distress. I would also request that you provide me with the
results of this investigation when it is completed.